Applicability of GST Audit

applicability of GST audit
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Last updated on May 16th, 2021 at 09:09 pm

Applicability of GST Audit


How is the audit defined in GST?

As per section 2(13) of CGST Act,2017

Audit as defined above mandates certain aspects like examination of records, returns, and other documents or furnished but there is no specific mention in the Act or the Rules about what should be the methodology of the audit or the manner of reporting. Only a format for reconciliation statement certificate in Form GSTR 9C is notified.


Applicability of GST Audit

As per section 35(5) of CGST Act, 2017 – every registered person whose turnover during a financial year exceeds the prescribed limit  shall get his accounts audited by CA or a Cost accountant and shall submit

  • A copy of the audited annual accounts
  • Duly certified reconciliation statement u/s 44(2)
  • Other documents as may be prescribed and required

As per section  44(2) of CGST Act, 2017 – every registered person who is required to get his accounts audited u/s 35(5), shall electronically furnish

  • Annual return (GSTR 9)
  • A copy of the audited annual accounts
  • A reconciliation statement (GSTR 9C)
    • reconciling the value of supplies declared in the return furnished for the financial year with the audited annual financial statement, and such other particulars as may be prescribed.

As per Rule 80(3) of the CGST Rules, 2017 – every registered person whose aggregate turnover during a financial year exceeds two crore rupees shall get his accounts audited as per section 35(5) and shall furnish electronically either directly through the common portal or through a Facilitation Centre notified by the Commissioner.

  • A copy of the audited annual accounts
  • A reconciliation statement (GSTR 9C) duly certified.


What is aggregate turnover under GST?

Aggregate turnover as defined in section 2(6) of CGST Act, 2017

In simple words, aggregate turnover means the total of Taxable Supplies(intrastate and interstate) add Exempt Supplies add Export Supplies add Branch Transfers less Taxes i.e. CGST, SGST, IGST, and cess

Note: Aggregate turnover does not include the turnover/ value of inward supplies on which tax is payable under the reverse charge mechanism. 

Note: The term turnover is not defined under the GST Act. 


What do you understand by a duly certified reconciliation statement?

When a Chartered Accountant or a Cost Accountant reconciles the values declared in the GST return furnished for the financial year with the audited annual accounts and prepares a report/statement in prescribed form GSTR 9C of reconciliation giving reasons for the same is called a duly certified reconciliation statement.


Overview of GST Audit


Form GSTR 9C GST Reconciliation Statement & Certification
Reconciliation of what? Reconciliation of details reported in

  • Annual returns (GSTR-9)
  • Audited Annual financial statements
If differences are found during reconciliation
  • CA will have to report the differences along with reasons for the same arising out of the reconciliation exercise and GST audit in GSTR-9C.
  • CA also needs to certify the additional GST liability if any.
Who needs to get GST Audit done? GST Audit will be applicable to those registered persons whose aggregate annual turnover exceeds Rs 5 crores in that financial year.
Who can do this? Chartered Accountant or Cost Accountant
How to file? File electronically on GST portal using DSC or EVC.
Supporting documents while filing GSTR 9C
  • A copy of the audited annual accounts and
  • Annual returns in GSTR-9.
Due Date 31st December of the year subsequent to the relevant Financial Year
Penalty for non-compliance with the audit requirement No specific penalty has been prescribed.

General penalty u/s 125 up to Rs. 25,000/- will be levied. A general penalty is imposed for contravention of any provisions or any rules of GST for which no specific penalty is separately provided.

Can additional taxes be paid with GSTR 9 or GSTR 9C?

No, payment of additional taxes or interest is not admissible while filing GSTR 9 or GSTR 9C. If while reconciling or filing an annual return, declaration of the difference in turnover/taxes/ITC would simply be construed as providing information to the proper officer about the same.  An additional payment of taxes in such cases can be done by filing FORM GST DRC-03 (for payment of tax and interest thereon). The proper officer will issue an acknowledgment in FORM GST DRC–04 for acceptance of payment made by the said person.

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About CA Ankita Khetan 196 Articles
Ankita is a Chartered Accountant in practice and holds a Diploma in IFRS (from ACCA, UK). She is also a Commerce PG and Certified Independent Director (from IICA). She holds a certification in Forex and Treasury Management. Her area of expertise is GST and Income tax. She is passionate about reading, writing, and sharing knowledge on areas related to finance and taxation.

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